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2002 (9) TMI 83 - DELHI HIGH COURTInterest On Borrowed Capital - We find that both the Commissioner of Income-tax (Appeals) and the Tribunal have noticed that by mutual consent, the parties had carried out certain changes in the original agreement and the interest was paid by the assessee in terms of the changed terms. The Assessing Officer had not doubted the genuineness of the subsequent arrangement but had rejected the assessee's claim only on the short ground that in view of the aforenoted restriction against change in terms, the original agreement could not be ignored. The Tribunal has come to the conclusion that there was no element of collusiveness in the parties agreeing to vary the terms of the initial agreement. We are of the view that this conclusion is essentially factual. The issue raised by the Revenue cannot be said to involve any question of law, much less a substantial question of law. It cannot be said that the finding of the Tribunal is without any evidence or material or is perverse
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